MrDJ
Legend
- Joined
- Apr 4, 2015
- Messages
- 23,628
Courtesy of FlavourArtUK on UKV
There has been much discussion regarding pricing of TRPR (TPD) compliant products.
Just to put a little perspective on what the costs are, here are some examples.
For a UK manufacturer to achieve TRPR (TPD) compliancy of 50 flavours in 3 strengths,
it would cost around £225,000 plus an annual fee of £9000 (Some might be paying more
than the £225k, others a little less).
Here's another turdlike bit of the regs that even the MHRA have admitted they weren't
fully aware of until recently....this affects retailers/resellers.
If you buy products from an EU manufacturer/supplier which have been Notified in their country,
but not Notified to the MHRA, each SKU must be Notified to MHRA before it can be sold in the UK.
The manufacturer can do this when they Notify in their country, but they can then ask you to pay for it,
which is £150 per SKU plus you still have the Annual fee to the MHRA.
The MHRA were originally under the impression that an EC-ID meant a compliant product could be sold in all
EU countries where the sale was legal without further need to Notify, but the TRPR 2016 has it buried deep within
its shitty little enclave. Some countries are free, others totally extortionate, as below.
Example: For a retailer to sell 50 flavours in 3 strengths (150 SKUs) bought from a member state,
you would still have to pay the MHRA £22,500 + £9,000 annual maintenance for the privilege!!
Per SKU:
Austria - Unknown
Belgium 165 €
Czech rep - No fees
Denmark 4956 € + annual maintenance
France 550€
Germany No fees
Greece 50€
Luxemburg 5000 €
Holland 44,85€
UK 174€ + annual maintenance
Here's another piece of crap buried at the end of the regs!
A number of member states have banned cross-border sales.
UK has not banned cross-border sales.
ARTICLE 24
Free Movement
1. Member States may not, for considerations relating to aspects regulated by this Directive, and subject to paragraphs 2 and 3 of this Article, prohibit or restrict the placing on the market of tobacco or related products which comply with this Directive.
2. This Directive shall not affect the right of a Member State to maintain or introduce further requirements, applicable to all products placed on its market, in relation to the standardisation of the packaging of tobacco products, where it is justified on grounds of public health, taking into account the high level of protection of human health achieved through this Directive. Such measures shall be proportionate and may not constitute a means of arbitrary discrimination or a disguised restriction on trade between Member States. Those measures shall be notified to the Commission together with the grounds for maintaining or introducing them.
3. A Member State may also prohibit a certain category of tobacco or related products, on grounds relating to the specific situation in that Member State and provided the provisions are justified by the need to protect public health, taking into account the high level of protection of human health achieved through this Directive. Such national provisions shall be notified to the Commission together with the grounds for introducing them. The Commission shall, within six months of the date of receiving the notification provided for in this paragraph, approve or reject the national provisions after having verified, taking into account the high level of protection of human health achieved through this Directive, whether or not they are justified, necessary and proportionate to their aim and whether or not they are a means of arbitrary discrimination or a disguised restriction on trade between the Member States. In the absence of a decision by the Commission within the period of six months, the national provisions shall be deemed to be approved.EN L 127/30 Official Journal of the European Union 29.4.2014
There has been much discussion regarding pricing of TRPR (TPD) compliant products.
Just to put a little perspective on what the costs are, here are some examples.
For a UK manufacturer to achieve TRPR (TPD) compliancy of 50 flavours in 3 strengths,
it would cost around £225,000 plus an annual fee of £9000 (Some might be paying more
than the £225k, others a little less).
Here's another turdlike bit of the regs that even the MHRA have admitted they weren't
fully aware of until recently....this affects retailers/resellers.
If you buy products from an EU manufacturer/supplier which have been Notified in their country,
but not Notified to the MHRA, each SKU must be Notified to MHRA before it can be sold in the UK.
The manufacturer can do this when they Notify in their country, but they can then ask you to pay for it,
which is £150 per SKU plus you still have the Annual fee to the MHRA.
The MHRA were originally under the impression that an EC-ID meant a compliant product could be sold in all
EU countries where the sale was legal without further need to Notify, but the TRPR 2016 has it buried deep within
its shitty little enclave. Some countries are free, others totally extortionate, as below.
Example: For a retailer to sell 50 flavours in 3 strengths (150 SKUs) bought from a member state,
you would still have to pay the MHRA £22,500 + £9,000 annual maintenance for the privilege!!
Per SKU:
Austria - Unknown
Belgium 165 €
Czech rep - No fees
Denmark 4956 € + annual maintenance
France 550€
Germany No fees
Greece 50€
Luxemburg 5000 €
Holland 44,85€
UK 174€ + annual maintenance
Here's another piece of crap buried at the end of the regs!
A number of member states have banned cross-border sales.
UK has not banned cross-border sales.
ARTICLE 24
Free Movement
1. Member States may not, for considerations relating to aspects regulated by this Directive, and subject to paragraphs 2 and 3 of this Article, prohibit or restrict the placing on the market of tobacco or related products which comply with this Directive.
2. This Directive shall not affect the right of a Member State to maintain or introduce further requirements, applicable to all products placed on its market, in relation to the standardisation of the packaging of tobacco products, where it is justified on grounds of public health, taking into account the high level of protection of human health achieved through this Directive. Such measures shall be proportionate and may not constitute a means of arbitrary discrimination or a disguised restriction on trade between Member States. Those measures shall be notified to the Commission together with the grounds for maintaining or introducing them.
3. A Member State may also prohibit a certain category of tobacco or related products, on grounds relating to the specific situation in that Member State and provided the provisions are justified by the need to protect public health, taking into account the high level of protection of human health achieved through this Directive. Such national provisions shall be notified to the Commission together with the grounds for introducing them. The Commission shall, within six months of the date of receiving the notification provided for in this paragraph, approve or reject the national provisions after having verified, taking into account the high level of protection of human health achieved through this Directive, whether or not they are justified, necessary and proportionate to their aim and whether or not they are a means of arbitrary discrimination or a disguised restriction on trade between the Member States. In the absence of a decision by the Commission within the period of six months, the national provisions shall be deemed to be approved.EN L 127/30 Official Journal of the European Union 29.4.2014